Liberty Bank, N.A. ("Bank" "we" "our" or "us)

Mobile Banking Application Privacy Notice

Last Updated: December 20, 2023

The Bank’s mobile banking application (the “App”) helps you manage your money, view your transactions and accounts, making it easy to manage your finances on the go.

This Mobile Privacy Notice (“Privacy Notice”) only applies to information we collect in this App and electronic communications sent through this App and is intended to supplement our separate Privacy Policy and any other disclosures you may have already received in connection with online banking or other services. The specific capabilities of the Services available to you in the App may vary depending on the specific relationship you have established with the Bank. You can find more information about the Bank’s Privacy Policies and your choices at the Bank’s website (www.libertybk.com) or by contacting the Bank at (800) 735-2465.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this Policy. This Policy may change from time to time (see Privacy Notice Updates below).

Depending on the Services you sign up for the App may allow you to:

get real-time balances for your accounts
manage your money
view your transactions and statements
make transfers
pay your bills and manage billers
pay other people
deposit a check
manage cards
locate branches and ATMs
receive alerts

THE TYPES OF INFORMATION THE APP COLLECTS

The App may collect personal information from you in the following ways:

(a) Personal Information You provide to us.

The App may collect personal information from you, such as your first and last name, address, e-mail, User IDs, and telephone number. Device images/videos may be accessed when you deposit a check or use a QR code to make peer to peer payments using Zelle or other payments functionality. Device contacts may be accessed when you to make peer to peer payments using Zelle or other payments functionality. Device location may be accessed to detect and prevent card transaction fraud and also to provide branch and ATM locations.
The App may collect the financial and transaction information necessary to provide you with the Services, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history.

(b) Personal Information Collected Via Technology. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services when you use the App, such as:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
Local storage technologies, like HTML5 that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect your location information when you use the Services; for example, to provide our fraud detection services. If you do not want the App to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

HOW THE APP USES YOUR INFORMATION

(a) General Use. In general, the App uses your personal information to respond to your requests as submitted through the Services, to provide you the Services you request, and to help serve you better. The App uses your personal information in the following ways:

facilitate the creation of, secure and maintain your account;
identify you as a legitimate user in our system;
provide improved administration of the Services;
provide the Services you request;
improve the quality of experience when you interact with the Services;
send you administrative e-mail and/or push notifications, such as security or support and maintenance advisories

(b) Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements and internal policies;
enforce the terms and conditions that govern the Service or the App; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

(c) Creation of Non-Identifiable Data. The App may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in its discretion.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We disclose your personal information as described below.

(a) Third Party Service Providers. We may share your personal information with third party or affiliated service providers that perform services for or on behalf of us, for the purposes described in this Privacy Notice , including: to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the App.

(b) Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If our company, business or assets is acquired by another company, that company will possess the personal information collected by us and the company will assume the rights and obligations regarding your personal information as described in this Privacy Notice and subject to any additional applicable legal requirements that might apply to that personal information.

(c) Authorities and Others. Regardless of any choices you make regarding your personal information, we may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above.

LINKS TO OTHER SITES

The Services may contain links to third party websites. When you click on a link to any other website or location, you will leave the Services and go to another site and another entity may collect personal and/or anonymous information from you. The App’s provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, does not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Notice do not apply to these outside websites. We encourage you to read the privacy notice of every website you visit.

YOUR CHOICES REGARDING YOUR INFORMATION

You have several choices regarding use of information on the Services.

(a) How We Respond to Do Not Track Signals. Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communications. We currently do not take action in response to these signals. However, we may revise its policy on responding to these signals.

(b) Opting Out of Email or SMS Communications. If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the "unsubscribe" link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under "Contact Us" below. If you provide your phone number through the Services, we may send you notifications by SMS, such as to provide a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the Services.

(c) Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the Services.

SAFEGUARDS AND RETENTION

We implement reasonable administrative, technical and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information. Federal laws and regulations require that US financial institutions retain original, active, and historical records. Your personal and financial data may be retained for a period of up to five to ten years, depending on applicable laws, regulations and legitimate business needs.

A NOTE ABOUT CHILDREN

The Services are not directed towards individuals under the age of 18, and we do not intentionally gather personal information about visitors who are under the age of 18. If a child under 18 submits personal information to us and we learn that the personal information is the information of a child under 18, we will attempt to delete the information as soon as possible.

PRIVACY NOTICE UPDATES

This Privacy Notice is subject to occasional revision. We may notify you, in our sole discretion, of any material changes of our collection, use, or disclosure of your personal information by posting an updated Privacy Notice on the App or sending you a copy of the updated Privacy Notice by written or electronic communication. You are responsible for ensuring that we have an up-to-date, active, and deliverable mailing and/or email address. Your continued use of the App or the Services following notice of any such changes shall indicate your acknowledgement and agreement to any changes to this Privacy Notice.

CONTACT US

If you have any questions or complaints about this Privacy Notice or the Bank’s data collection or processing practices, or if you want to report any security violations to us, please contact us at (800) 735- 2465, or by mail at:

Liberty Bank, N.A.

355 S Grand Ave Suite 2825

Los Angeles, CA 90071